Privacy Policy

OVERVIEW

In order to operate the Oceanwide service and to reduce the risk of fraud, Oceanwide Inc. (“Oceanwide” or “we”) must ask you to provide us information about yourself and/or your organization. This Privacy Policy describes the information we collect and how we use that information.

Oceanwide takes the privacy of your personal and corporate information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the www.oceanwide.com Web site, whether the services are offered by Oceanwide Inc.as well as all of its subsidiaries, including Oceanwide USA Inc..

By accepting the Privacy Policy and User Agreement during registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Oceanwide User Agreement. This Privacy Policy will take effect on March 1, 2006 and supersedes any previous Privacy Policy in effect.

Please note that your personal information will be stored and processed on our computers in the United States or Canada. The laws on holding personal data in the United States or Canada may be less stringent than the laws of your country but Oceanwide will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for any of our services.

Notification of Changes

This policy may be revised over time as new features are added to the Oceanwide service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail with at least 30 days’ notice of the amended Privacy Policy (if you have closed your Oceanwide account, you will not be contacted to notify you of the amended Policy and your personal information will not be used or disclosed in this new manner).

We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Oceanwide Web site at www.Oceanwide.com at any time for the most current version of our Privacy Policy.

Other pages on the Oceanwide Web sites include links to third party Web sites. These sites are governed by their own privacy statements, and Oceanwide is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.

INFORMATION WE COLLECT

Required Information

To open an Oceanwide account, you must provide your name, address, phone number, and e-mail address. In order to make payments through Oceanwide, you must provide credit card, debit card or bank account information. We also ask you to choose two different security questions to answer (such as your city of birth or your pet’s name) This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and checking account fraud, and to contact you should the need arise in administering your account.

Information About You From Third Parties

In order to protect all our customers against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with Oceanwide, we will use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to Oceanwide, and that the card has not been reported as lost or stolen.

If you incur a debt to Oceanwide, we will generally conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. Oceanwide, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to close an account based on information obtained during this credit review process.

Additional Verification

If we cannot verify the information that you provide, or if you request a withdrawal by check to an address other than your verified credit card billing address, we ask you to send us additional information by fax (such as your drivers’ license, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions online to help verify your information.

Web Site Traffic Information

Because of the way that World Wide Web communication standards work, when you arrive at or leave the Oceanwide Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the Oceanwide site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve our service and your experience with Oceanwide. We do not track the Web sites that you visit before or after you leave the Oceanwide site.

Our Use of “Cookies”

“Cookies” are small files of data that reside on your computer and allow us to recognize you as a Oceanwide customer if you return to the Oceanwide site using the same computer and browser. We send a “session cookie” to your computer if and when you log in to your Oceanwide account by entering your account and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don’t need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

We also use longer-lasting cookies to display your profile information on certain forms, so that you don’t have to retype the information each time when you log in to your Oceanwide account. Our cookie files are encoded so that your e-mail address and other information can only be interpreted by Oceanwide. We may, however, share cookie information regarding whether or not a certain user is already registered with Oceanwide with certain merchants with whom we have an official co-marketing relationship.

Customer Service Correspondence

If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Oceanwide to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

Questionnaires, Surveys and Profile Data

From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users’ interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

OUR USE AND DISCLOSURE INFORMATION

Internal Uses

We collect, store and process your personal information on servers located in the United States and Canada. We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to receive offers for special features or products, and 4) to improve our products and services. At your option we use the information you provide to access specific third party services on your behalf and perform the actions that you request us to perform.

We give access to individually identifiable information about our users only to those employees who require it to fulfill customer service requests.

Disclosure to Other Oceanwide Customers

We work with third party merchants to enable them to accept payments from you, including direct credit card payments. Merchants who use this service will share personally identifiable information you provide to them with Oceanwide in order to validate the information, assess the risks of your payment, or confirm the existence or status of your Oceanwide account. You permit Oceanwide to share information with the merchant on the validity of the personally identifiable information you provided to the merchant, and on the existence or status of your Oceanwide account.

Oceanwide does not store the personally identifiable information provided by these merchants to validate the existence of your account.

Disclosure to Third Parties Other Than Oceanwide Customers

Oceanwide will not sell or rent any of your personally identifiable information to third parties. Oceanwide will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission (and with other Oceanwide customers as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.

We share information with companies that help us process the transactions you request and protect our customers’ transactions from fraud, such as sharing your credit card number with a service that screens for lost and stolen card numbers. See “Information About You From Third Parties” in Section B above. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies.

We may disclose the information we collect, as described in Section B above, to companies that perform marketing services on our behalf.

We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity’s contact information (but not bank account or credit card information) to victims who request it.

We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.

When a user signs up for a co-branded version of Oceanwide through links to Oceanwide from our co-branded partner’s website, Oceanwide will share with the co-branded partner that user’s name, e-mail address and physical address in order to provide enhanced integration between Oceanwide’s services and the services of our co-branded partner. If you do not want your information shared with Oceanwide’s co-branded partner, you should sign up with Oceanwide directly and not through a link from our partner’s website.

We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).

As with any other business, it is possible that Oceanwide in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by Oceanwide, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section A above.

We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.

Our Contacts with Oceanwide Customers

We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of a Oceanwide account, to send you notice of payments that you send or receive through Oceanwide (including referral payments described below), to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

Internet Address Information

We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

INFORMATION AND SECURITY

Information Security

Oceanwide is committed to handling your customer information with high standards of information security. Your credit card and bank account information are stored only in encrypted form on computers that are not connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with industry standard and accepted mechanisms to guard your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes.

The security of your Oceanwide account also relies on your protection of your Oceanwide password. You may not share your Oceanwide password with anyone. Oceanwide will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the Oceanwide website, which will always have a URL beginning with www.oceanwide.com.

Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with www.oceanwide.com should be treated as unauthorized and suspicious and should be reported to Oceanwide immediately. If you do share your Oceanwide password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings, and also contact us right away as described in Section F below.

ACCESSING AND CHANGING YOUR INFORMATION

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your Oceanwide account, at any time by logging in to your account on the Oceanwide Web site and changing your preferences in the Profile page.

CONTACTING US

If you have any questions about this privacy statement, Oceanwide’s information practices, or your dealings with Oceanwide, you can contact us: